In Brief
The Supreme Court quashed five FIRs filed under the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, and the Indian Penal Code. FIR 224/2022 was quashed as it was lodged by a person (Himanshu Dixit, head of Vishwa Hindu Parishad) not authorized under Section 4 of the Act, which restricts FIR-lodging to aggrieved persons and their family. FIRs 55/2023 and 60/2023 were quashed as subsequent FIRs for the same incident, violating the principle against multiple FIRs. FIRs 54/2023 and 47/2023 were quashed due to manifest mala fide investigation, evidenced by cyclostyled witness statements and fabricated affidavits. The Court held that religious freedom is a matter of personal autonomy protected by Articles 21 and 25, and restrictions on who can lodge conversion complaints reflect constitutional recognition of this sphere. The judgement reinforces that inherent powers to quash FIRs extend to cases involving abuse of process and mala fide investigation, even after chargesheet filing, and that Article 32 writ jurisdiction is maintainable to challenge criminal proceedings violating fundamental rights.
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